Memo Detail

Full Document:PDF Link
RCRA Online Number: 11563
Title: SQG COMPLIANCE WITH TC RULE
Document Date: 1990-09-20
To: Huber
From: Lowrance
Organization of Recipient: Petroleum Marketers Association of America (PMAA)
Description: A fuel oil leak from a household tank is exempt household hazardous waste (HHW). EPA does not determine if a particular waste is characteristic. The hazardous waste determination is the generator's responsibility. SQGs that are newly subject due to the toxicity characteristic (TC) rule had until 11/2/90 to notify the region. SQGs were granted an additional three months to comply with the TC Rule. Spilled petroleum products that are reclaimed from contaminated soil and used to produce fuels are not solid wastes.
Regulatory Citation(s): 261.4(b)(1), 261.2(c)(2)
RPPC Number: 9441.1990(26)
Official ORCR Policy: Yes
Associated Topic(s): Characteristic Wastes, Exclusions (RCRA), Hazardous Waste, Hazardous Waste Recycling, Small Quantity Generators (SQG)